Marcus V. and Polly A. Booker - Page 7

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          that one year she gave her mother approximately $6,200 to assist            
          in paying her mortgage and electric bill; however, petitioners              
          could not recall the exact year of the donation or provide any              
          written substantiation for such a payment.                                  
               Section 151(c) allows for dependency exemption deductions in           
          certain circumstances.  The father or mother of a taxpayer may              
          qualify as a dependent of the taxpayer if the taxpayer provides             
          over half of that individual’s support in the calendar year for             
          which the deduction is sought.  Sec. 152(a)(4).  Although                   
          petitioners testified they provided support to Mrs. Booker’s                
          mother, their testimony was vague, and they did not establish a             
          definite amount for either year.  In addition, petitioners                  
          presented no written evidence to substantiate their                         
          contributions.  Mrs. Booker acknowledged that Ms. Mayfield                  
          received at least $700 a month in unrelated support but failed to           
          establish the amount of support Ms. Mayfield received from all              
          sources during the years at issue.  On this record, petitioners             
          failed to establish they contributed over half of Ms. Mayfield’s            
          support for each of the years in question.  Respondent,                     
          therefore, is sustained on this issue.                                      
               The next issue concerns itemized deductions claimed by                 
          petitioners on Schedules A, Itemized Deductions, of their 1999              
          and 2000 income tax returns.  Petitioners claimed substantial               
          deductions on their 1999 and 2000 returns under section 170 for             

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